Preparing for In Depth Assessments

Transcription

1 Preparing for In Depth Assessments Karen Marshall Director of Governance and Compliance

2 V In Depth Assessment

3 Preparing for an IDA take a deep breath

4 Background and context Key stages in the process Preparation Document requests Site visit Board / Committee meeting Feedback / follow up whg s experience

5 Background and context Stock transfer ,000 homes, mainly in Walsall Turnover 92m 250m bond Development programme: 1900 homes ( ) 641 colleagues (FTE) Governance review part way through

6 In Depth Assessments aka Deep Dive Now part of HCA s regulatory engagement New way for HCA to gain assurance Every three to four years 12 pilots Summer 2015 started carrying out for real whg was one of the first!

7 IDAs: why? Cosmopolitan: lessons learnt Developing beyond its capacity Losing money, running out of cash Delays in putting new funding in place Complexity: group structures & funding Board skills not kept pace Board didn t understand interactions of risks Lack of challenge to growth-focused Exec

8 HCA: Regulating The Standards Key operational approaches Review of quarterly surveys Stability checks In-depth assessments

9 Getting ready Be prepared: What areas are the HCA likely to be interested in? Generally What are the current / emerging issues? Specific to your organisation whg: Governance review Rent reduction / revised Business Plan

10 IDA outline Notification and request for Board and AAC meeting dates Document request. further document request Agenda? / Scope? Site visit.. more documents requested Board or Committee meeting Outcome and feedback

11 Notification - timescales 6 July 2015 telephone call advising whg in IDA programme. Scope and documents required to be advised in due course 15 July advising immediate IDA work being re-assessed in the light of budget announcements 11 August telephone call advising IDA site visit 12 & 13 October October 2015

12 Preparation Advance preparation: documents map to the 5 streams of enquiry Strategy Structure Financial resilience Risk profile and mitigation Governance

13 Document request(s) Specific document eg Development Strategy Or Evidence to show..

14 Documents requested (1) List 1: requested 12 Aug. provide by 19 August 10 issues / topics: 16 documents including Structure charts Risk report Performance report Report on compliance with Code Audited accounts Treasury Policy Management accounts (latest) Latest report to Board on the development programme

15 Documents requested List 2: requested 9 Sept. Provide by 21 Sept 24 issues / topics: 58 documents including Full set of board papers and minutes Asset Management Strategy Board member information including skills assessment and succession planning Update on assets and liabilities register Summary and recommendations from most recent governance review Latest board paper on welfare reform evidence of Board leading on VFM

16 Documents requested- the Group Audited accounts for each Group member Overview of management and reporting arrangements between parent and each subsidiary Appointment and removal of board members Board member details / skills Employer status of subsidiaries Asset ownership Turnover and potential exposure External borrow and other liabilities Guarantees provided within the group Cross default provisions Governance and reporting arrangements including any legal advice

17 Overview of whg Walsall Housing Group Limited Visionary Investment Enhancing Walsall Limited (VIEW) whg Trading Company Limited whg Developments Limited whg Treasury PLC Buy For Good CIC Registration Details Registered Provider L4389 Company Limited by Guarantee Companies House registration number Registered Charity Exempt charity and registered society under the Co-Operative and Community Benefit Societies Act 2014 Registration number 29907R Company Limited by Shares Companies House registration number Company Limited by Shares Companies House registration number Public Company Limited By Shares Companies House registration number Company Limited by Guarantee not having a Share Capital Companies House registration number Purpose Provide housing, accommodation and associated facilities and amenities Administer the VAT shelter fund to benefit local community projects Carry out commercial and similar activities on behalf of whg Carry out development activity on behalf of whg Special purpose vehicle for issuing listed bonds on behalf of whg Deliver social value through innovative and collaborative procurement initiatives Member Details and Voting Rights Three constituent Groups of Members each with 33⅓ voting rights: Independent Members Members are: Walsall Housing Group Wholly owned by Walsall Housing Group Limited Wholly owned by Walsall Housing Group Limited Wholly owned by Walsall Housing Group Limited Wholly owned by Walsall Housing Group Limited Tenant members Members appointed by whg (i.e. Board Members) Council Member Reporting Arrangements WHG Board has final approval of its investment strategy, annual budget, annual accounts and statement of internal controls WHG Board has final approval of its business strategy, annual budget, annual accounts and statement of internal controls WHG Board has final approval of its business strategy, annual budget, annual accounts and statement of internal controls WHG Board has final approval of its business strategy, annual budget, annual accounts and statement of internal controls WHG Board has final approval of its business strategy, annual budget, annual accounts and statement of internal controls Minutes of all Board meetings are reported to WHG Board Minutes of all Board meetings are reported to WHG Board Minutes of all Board meetings are reported to WHG Board Minutes of all Board meetings are reported to WHG Board Minutes of all Board meetings are reported to WHG Board Employer Status All colleagues are employed by Walsall Housing Group Limited No employees No employees No employees No employees No employees

18 Document or evidence of Getting the documents right Is the information readily accessible? Does it answer the question / give the assurance sought? Does it give too little / too much information? What will it lead to next? Is it clear? summary / context / timeline / progress to date /further plans Have the right colleagues read and checked the documents (including someone who will read them as the regulator will)?

19 Submitting the documents Have a single point of contact Create document list and cross reference to HCA list and file names Upload via NROSH

20 Preparation for site visit Briefing the Board Briefing colleagues Briefing notes IDA Briefing Notes 1. IDA: five key areas 2. Corporate Plan 3. Future strategic direction 4. Governance structure 5. Risk and risk management 6. Treasury management 7. VFM 8. Compliance with regulatory standards 9. Compliance with NHF Code 10. Governance review 11. Asset management 12. Assets and Liabilities register 13. Welfare reform 14. Sources of assurance 15. Work in progress (examples) 16. Stress testing 17. Covenant compliance Compiling more documents Practice interviews external support? Making the team welcome

21 Site visit what to expect Well prepared team not just the documents sent for IDA but earlier returns too will spot any inconsistencies / discrepancies Lots of questions challenging and detailed Triangulation documents / follow up with questions to Board and Exec Requests for more documents

22 The agenda Received 7 October: on site 12/13 October Sessions with: exec team asset management and development colleagues finance and treasury management colleagues Chair member(s) of Governance Review Working Group other: to be confirmed (CE, Director of Governance, lead person for VFM)

23 Key areas Strategic decision making Financial strength Budget / Business Plan Covenants and golden rules Treasury management Risk and stress testing Assets and liabilities register Asset management Development Community work Gas servicing performance Governance review (Chair and Board members)

24 Follow up Clarification and more documents Submission of revised Business Plan HCA attended Audit and Assurance Committee meeting observing this meeting to enable us to get a fuller understanding of how your board structure operates

25 The outcome HCA internal meeting to present findings Telephone call to advise of outcome Judgment published on HCA website Reg Code Provider Gov Via Type of Publication Status Date Route L4389 Walsall Housing Group Limited G1 V1 Strapline RJ Published 16/12/2015 In Depth Assessment Session to feedback and discuss the process for updating governance and viability straplines

26 What to expect? High level engagement, feels different Positive challenge, insightful, learning experience Resource intensive for exec, Board & governance Burden of proof of compliance lies with RP Tailored to each organisation Documents, questions, follow-up How is the Board assured? Looking to triangulate Or query inconsistencies

27 Good luck For more information contact Karen Marshall /